IG, Regulations & Compliance

Should you archive departing employee data?

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IG, Regulations & Compliance

Should you archive departing employee data?

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  2. Should you archive departing employee data?
A departing employee leaves huge amounts of ESI behind when they leave. Should companies take special care to preserve this data?

Many of today’s employees are information workers — employees who use or create information to aid in decision-making or to influence organizational courses of action.

Not only do information workers create and receive huge amounts of electronic data on a daily basis, but they also tend to keep much of that data for reference and reuse. So, over a relatively short period of time, an information worker can accumulate tens or hundreds of gigabytes of electronically stored information (ESI). But what should an organization do with departing employee data?

While much of this data — containing duplicates, revisions and expired or old content — has little potential value to the organization, a percentage of it may contain intellectual property, corporate history and know-how, documents subject to regulatory or legal retention or content with direct business value.

Organizations tend to handle departing employee data one of two ways: ignore it or delete it. A standard practice for many companies when an employee leaves is to close all of their accounts and repurpose or reimage their computer equipment, effectively destroying the departing employee’s data. For example, a company might close an employee’s Office 365 account and transfer that license to a new employee. The problem with this practice is that the employee’s OneDrive cloud account will automatically be wiped, deleting all files saved in the cloud. The departing employee’s cloud-based email account will also be closed, deleting all live and archived email held in Office 365.

On the other hand, many IT personnel complain that file shares and email servers are congested with ex-employee files and email accounts because their company doesn’t have a policy to address departing employee data.

Some companies have found out the hard way that blindly deleting ex-employee data can adversely affect business. In one personal example, I received a call from a panicked ex-employer asking if I had a copy of the complex Excel ROI model I had created six months before I had left the company. (I did not, and told them so.) It turns out they had reimaged my laptop without backing it up and had lost the ROI model. They now had a large deal that depended on being able to run that model — and they didn’t have it.

Corporate legal departments are leading the way in putting policies in place to capture and archive departing employee data for a retention period based on the statute of limitations for wrongful termination lawsuits, in case a terminated employee later sues. The policies ensure that email accounts, archives, cloud accounts and computer equipment are all mined for potentially responsive data before it is lost. Smart information governance professionals will take this as a cue that its time to start proactively considering and managing the data of departing employees.


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